The following lays out the conceptual steps of the
phased cumulative tolerance reassessment process, guided by the preceding
principles. Thus, for example, stakeholder consultations and peer review
could be built in throughout the process described here.

A phased approach would consider initially
the tolerances associated with each individual OP.

This approach requires that the tolerances
for each OP meet the safety standard based on food only, and that worker
and ecological risk are managed to acceptable levels for all
uses.

-- If the risk cup is exceeded, then use patterns would
need to be changed and/or uses dropped to ensure that all tolerances meet
the safety standard.

-- If worker or ecological risk is identified, then
such risks would need to be mitigated to acceptable levels under FIFRA.

Reduce potential risks from residential and
groundwater exposure.

Cumulative risk assessment for all OP pesticides
based on food alone would be conducted (after the individual chemical risks
for food, worker and ecological effects have been managed).

-- An approach might be to allocate a percent of the
"risk cup" by commodity and manage risks by commodity.

A cumulative risk assessment incorporating
refined residential and groundwater data would be conducted after cumulative
risks for the OP pesticides based on food alone have been
managed.

-- If the tolerances still do not meet the safety standard,
then such risk would be managed to acceptable levels through application
of the decision-making criteria and appropriate regulatory action.